ESG reporting · who is in scope
Which companies have to do ESG reporting in the UK?
Listed companies, and large private companies and LLPs, are the main ones.
SECR reaches quoted companies and any unquoted company or LLP that exceeds two of £36m turnover, £18m balance sheet and 250 employees; climate disclosure starts above 500 employees; gender pay gap at 250 employees; the modern slavery statement at £36m turnover.
Small and medium-sized companies have no statutory ESG duty.
By organisation type
Which kinds of organisation are in scope?
Listing decides UK SRS; size decides almost everything else.
| Organisation | ESG duties that usually reach it | Key test |
|---|---|---|
| Listed in UKLR 6, 14, 15, 16 or 22 | UK SRS on comply or explain from 2027; SECR at any size; climate disclosure above 500 employees | Listing category, no size limb |
| AIM company | SECR as an unquoted company; climate disclosure above 500 employees; not UK SRS | s.414CA(1)(e) |
| Large private company | SECR; the s.172(1) statement; climate disclosure above 500 employees and £500m turnover | Exceeds two of £36m, £18m, 250 |
| Large LLP | SECR in an energy and carbon report; climate disclosure above 500 employees and £500m | SI 2008/1911 reg 12B |
| Any employer of 250 or more | Gender pay gap; ESOS | Headcount on 5 April |
| Any supplier with £36m turnover | Modern slavery statement | SI 2015/1833 |
| Pension scheme of £1bn or more | A climate report by the trustees | SI 2021/839 |
| FCA-authorised firm | The anti-greenwashing rule; SDR for asset managers | FCA ESG sourcebook |
| Small or medium-sized company | No statutory ESG duty; customers may ask | Meets two of the three |
One LLP
Does ESG reporting reach a professional services LLP?
An LLP with 320 people and £52m turnover owes four duties, and climate disclosure is not one of them.
It is an illustration, not a real organisation.
LLPs are the population most often left out of ESG summaries, because the duties reach them through separate LLP regulations rather than the Companies Act sections most guides quote.
The LLP rules are set out on SECR reporting requirements.
- 1
Is it listed?
No. An LLP is not in a UK Listing Rules category, so UK SRS is voluntary for it (DBT).
- 2
SECR?
Yes. With 320 members and staff on average, £52m turnover and a £22m balance sheet it exceeds all three tests, so it prepares an energy and carbon report (SI 2008/1911 reg 12B).
- 3
Climate disclosure?
No. The LLP limb needs more than 500 employees and turnover over £500m (s.414CA).
- 4
ESOS?
Yes. It has at least 250 employees, so it is a large undertaking (Sch 1).
- 5
Modern slavery and gender pay gap?
Yes to both: £52m is over £36m (SI 2015/1833), and it has 250 or more employees on 5 April (SI 2017/172).
The tests
Why do the thresholds not line up?
Each instrument writes its own test, with its own operator: “exceeds two of”, “more than”, “at least”, “not less than”.
A company can be inside one duty and outside the next on the same figures.
SECR’s test did not move when the Companies Act size limits rose on 6 April 2025, so a company can be medium-sized for its accounts and still inside SECR.
At exactly 250 employees, ESOS applies while SECR’s employee limb is still met; the worked comparison is on ESG reporting requirements.
Size tests
SECR
Size tests
Section 172(1)
Your company
Does your company need ESG reporting?
Enter one year’s figures and see which duties they point to.
One year’s figures · eight UK duties
5 of 8 tests point to a duty on these figures.
No UK SRS duty for this category or for an unlisted entity.
The standards remain available for voluntary use.
Fewer than two conditions are met, so these figures point to a SECR duty: UK energy, emissions and an intensity ratio in the directors’ report.
At or under the 500-employee floor, which applies to every limb, so this duty does not arise.
The large-undertaking test is met.
For Phase 4 it is taken on 31 December 2026 across the UK group, with compliance notified by 5 December 2027.
Total turnover is not less than £36 million, so a supplier of goods or services publishes a slavery and human trafficking statement each financial year.
Subsidiaries’ turnover counts.
250 or more employees: a private or voluntary-sector employer publishes six figures within 12 months of the 5 April snapshot date.
The count is taken on that date, not as an average.
Larger than medium-sized on these figures, so the strategic report includes a statement of how the directors had regard to s.172(1)(a)–(f), including the environment.
Not applicable: the Code reaches the commercial companies and closed-ended investment funds categories only.
One year, one entity, literal readings.
It does not aggregate groups, apply the two-year rules or the ESOS snapshot date.
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A pointer to the instruments, not legal advice: group structures and two-year averaging change answers.
Listing decides UK SRS, size decides the rest, and each duty draws its own line.
- UKLR 6, 14, 15, 16, 22
These listing categories report against UK SRS or explain
From periods beginning 1 January 2027. - Two of £36m, £18m, 250
Exceeding two brings an unquoted company or LLP into SECR
Quoted companies are in at any size. - 250 employees
Gender pay gap and ESOS start at this headcount
Measured differently by each. - SMEs
No UK statute requires a small or medium-sized company to report ESG
Customer requests are not law.
Frequently asked
Who needs ESG reporting? The questions people ask
Which companies have to do ESG reporting in the UK?
Each duty has its own population.
Quoted companies, and unquoted companies and LLPs that exceed two of £36 million turnover, £18 million balance sheet and 250 employees, report energy and carbon under SECR.
Named companies with more than 500 employees make climate disclosures.
Employers of 250 or more report their gender pay gap, and commercial organisations with turnover of £36 million or more publish a modern slavery statement.
Listed companies in five categories report against UK SRS or explain, from 2027.
Who needs to do ESG reporting?
Large and listed organisations, mainly.
The tests are size (turnover, balance sheet, employees), listing category, sector (pension schemes, asset managers, installations under the UK ETS) and activity (importing CBAM goods, placing packaging on the market, bidding for large government contracts).
Who is required to file an ESG report?
Nobody files a document called an ESG report in the UK.
SECR and the climate disclosures are filed as part of the annual report at Companies House.
The modern slavery statement is published on the website, gender pay gap figures on the government’s service, and ESOS compliance is notified to the Environment Agency.
Do AIM companies have to do ESG reporting?
Yes, through company law rather than the listing rules.
AIM is not on the Official List, so the FCA’s UK SRS rule does not reach an AIM company.
But SECR treats it as unquoted, so it reports if it exceeds two of the three SECR tests, and the AIM limb of section 414CA brings climate disclosure above 500 employees.
Do LLPs have to do ESG reporting?
Large LLPs do.
SECR reaches an LLP that exceeds two of £36 million, £18 million and 250 employees, in a separate energy and carbon report.
Climate disclosure reaches an LLP with more than 500 employees and turnover over £500 million.
ESOS, modern slavery and gender pay gap can all apply to an LLP on their own tests.
Do SMEs need ESG reporting?
No UK statute requires a small or medium-sized company to publish ESG information.
The pressure arrives from customers, lenders and tenders, which can ask for data a company is not legally required to publish.
Do charities have to do ESG reporting?
A charity that is a company follows the same company-law tests; a charity that carries on a business supplying goods or services, with total turnover of £36 million or more, publishes a modern slavery statement; and a charity with 250 or more employees reports its gender pay gap.
There is no separate ESG duty for charities.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- Financial Conduct AuthorityPS26/19
UK SRS on comply or explain for UKLR 6, 14, 15, 16 and 22.
- Financial Conduct AuthorityPS26/19 (PDF), ¶3.6
No size limb: listing category alone decides.
- Financial Conduct AuthorityUK Listing Rules
The listing categories.
- Department for Business and TradeUK SRS guidance
Voluntary use for every other entity.
- legislation.gov.ukSI 2008/410, Schedule 7
SECR for quoted and unquoted companies.
- legislation.gov.ukSI 2008/410, Schedule 7 paragraph 20B
The two-of-three exemption.
- legislation.gov.ukSI 2008/1911, regulation 12B
SECR for large LLPs.
- legislation.gov.ukCompanies Act 2006, section 414CA
The climate disclosure population.
- legislation.gov.ukCompanies Act 2006, section 414CB
The disclosures themselves.
- legislation.gov.ukCompanies Act 2006, section 414CZA
The section 172(1) statement.
- legislation.gov.ukCompanies Act 2006, section 465
The medium-sized test.
- legislation.gov.ukESOS Regulations 2014, Schedule 1
Large undertakings.
- legislation.gov.ukModern Slavery Act 2015, section 54
Commercial organisations supplying goods or services.
- legislation.gov.ukSI 2015/1833
The £36m turnover threshold.
- legislation.gov.ukSI 2017/172
Private and voluntary sector employers of 250 or more.
- legislation.gov.ukSI 2021/839
Pension scheme trustees.
- Financial Conduct AuthoritySDR regime
Asset managers and authorised firms.
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